We are committed to safeguarding the privacy of our website visitors and customers.
1.1 This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and customers. In other words, where we determine the purposes and means of the processing of that personal data.
1.3 In this policy, "we", "us" and "our" refer to the owner of this website and Twiggd, Tara McIntosh.
2.1 This document was created using a template from SEQ Legal (https://seqlegal.com).
3. How we use your personal data
3.1 In this Section 3 we have set out:
(a) the general categories of personal data that we may process;
(b) the purposes for which we may process personal data; and
(c) the legal bases of the processing.
3.2 We may process data about your use of our website ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your visits. The source that provides us with this usage data is Visitor Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
3.3 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). The enquiry data may be processed for the purposes of offering and selling relevant goods and/or services to you. The legal basis for this processing is consent.
3.4 We may process information relating to transactions, including purchases of goods and services, that you enter into with us. ("transaction data"). The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records o f those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
3.5 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters ("notification data"). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.
3.6 We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
3.7 Please do not supply any other person's personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
We Will never sell or rent your personal data to third parties.
4.1 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.2 Financial transactions relating to our sales and services may be handled by our payment services providers, Paypal, Sumup. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers' privacy policies and practices at https://www.paypal.com/uk/webapps/mpp/ua/privacy-prev https://sumup.co.uk/privacy/
4.3 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject ie accounting purposes, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. International transfers of your personal data
In this Section 5, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.1 Some of the hosting facilities for our website are situated in the USA. The European Commission has made an "adequacy decision" with respect to the data protection laws of this country. Transfers to the USA will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission. Sharing of Personal Information from Wix subsidiaries and affiliated companies in the European Union and Switzerland to Wix’ United States subsidiary, adheres to the EU-US and Swiss-US Privacy Shield frameworks. A copy of which you can obtain here:
Sumup - https://sumup.co.uk/privacy/
6. Links To Other Sites
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
7. Retaining and deleting personal data
7.1 This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
7.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We will retain your personal data as follows:
(a) Emails (or communications sent via the contact form on this site) which contain your name, email address and/or other personal information will be retained for a minimum period of 6 months following the end of our communication, and for a maximum period of one year following the end of our communication.
(b) Any invoices which occur (which may contain your name, email address, postal address and phone number) due to your purchase of goods or services will be kept for a minimum of 7 years due to legal requirements put upon us by HMRC for tax purposes
(c) Any dispatch notes downloaded and printed from our third party selling platforms will be deleted at the end of each month.
7.4 Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
8.1 We may update this policy from time to time by publishing a new version on our website.
8.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9. Your rights
9.1 In this Section 8, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
9.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
9.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge. You can request for your personal data to be made available to you by contacting Twiggd email@example.com
9.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
9.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
9.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
9.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
9.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
9.9 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
9.10 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
9.11 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal. If you have consented for us to contact you by joining our mailing list we will enable you to remove consent at any time by unsubscribing via a link on each correspondence or by contacting us directly at firstname.lastname@example.org
9.12 You may exercise any of your rights in relation to your personal data by written notice to us email@example.com, in addition to the other methods specified in this Section 8.
10. About cookies
10.1 A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
10.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
10.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
11. Cookies that we use
We use Visitor Analytics to analyse the use of our website. Visitor Analytics gathers information about our website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website.
Visitor Analytics data proccesing agreement is available at: https://www.visitor-analytics.io/wix-data-processing-agreement/
The relevant cookies are:
wix_visitor_analytics_WEBSITE_UNIQUE_HASH The Visitor Analytics App uses this cookie in order to track the actions that the user is doing on the website such as the pages visited, frequency and so on.
Cookies used for this purpose are:
wix_ignore_Visits_UniqueHash The Visitor Analytics app places this cookie at the request of the user for a specific website, in order to disable Visitor Analytics website analytics tracking for that specific website.
12. Managing cookies
12.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari); and
12.2 Blocking all cookies will have a negative impact upon the usability of many websites.
13. Our details
13.1 This website is owned and operated by Tara McIntosh.
13.3 Our principal place of business is at 29 Greenend Gardens, Edinburgh, EH17 7QQ.
.13.4 You can contact us:
(a) by post, to the postal address given above
(b) using our website contact form
(d) by email, using the email address published on our website
14. Data protection officer
14.1 Our data protection officer's contact details are: firstname.lastname@example.org.